The Vietnam Competition Commission (VCC) has published its 2025 annual report (Report), which was released publicly on 6 July 2026. The Report offers valuable insight into enforcement trends and the regulatory outlook for businesses operating in or transacting into Vietnam. While the Report outlines a wide range of VCC activities including in competition and consumer protection, this Alert focuses on the competition regime.
Regulatory Changes
Legislative reform was a major theme of the VCC’s year. Of particular note, the VCC led the drafting of a Decree amending Decree No. 75/2019/ND-CP on administrative sanctions in the field of competition, which the Ministry of Industry and Trade submitted to the Government on 26 November 2025. In parallel, on 8 December 2025 the Ministry submitted a draft Decree to replace Decree No. 40/2018/ND-CP on the management of multi-level marketing activities, designed to strengthen decentralisation to local government and to reduce and simplify administrative procedures and business conditions.
Competition Enforcement
The VCC received 273 economic concentration notifications in 2025, the majority filed through the online public services portal. Of these, 168 were cleared at the preliminary assessment stage, 12 proceeded to official (Phase 2) assessment, and 48 dossiers were returned. Notably, 7 economic concentrations were approved subject to conditions following official assessment — a significant signal that the VCC is willing to use remedies to permit economics concentrations to proceed rather than simply rejecting transactions outright. The VCC was continuing its assessment of 50 dossiers (including 5 dossiers at the official assessment stage).
According to the Report, among the 175 economic concentration notification dossiers for which the VCC issued notices permitting implementation or permitting implementation subject to conditions, 72% were in the form of acquisitions, and approximately 56% were horizontal in nature.
The VCC verified 72 cases involving signs of competition law violations in 2025, spanning anti-competitive conduct (11), economic concentration regulatory violations (13) and unfair competition conduct (48). Investigation decisions were issued in 15 cases (13 in relation to unfair competition cases).
The Report noted two exemptions granted by the VCC for otherwise prohibited anti-competitive agreements 1) between Vietnam Airlines and Air France, and 2) between Vietnam Airlines and China Southern Airlines, covering certain Vietnam–France and Vietnam–China routes — a reminder that the exemption mechanism under the 2018 Competition Law (Competition Law) is available and functioning.
Plans for 2026
Businesses should watch a substantial legislative pipeline for 2026 including: amendments to the Competition Law itself (within an omnibus law expected before the National Assembly in August 2026), amendments to Decree 35/2020 (the Competition Law’s implementing decree), a new decree on administrative sanctions in the field of competition (amendments to Decree 75/2019) have, at the time of the writing of this alert, already been promulgated (Decree 102/2026/ND-CP was issued on 31 March 2026 and became effective on 20 May 2026), and a replacement decree on multi-level marketing is also already effective (Decree No. 137/2026/ND-CP on management of multi-level marketing, which was issued on 7 April 2026 and took effect on 1 July 2026).
Outside the scope of the Report, it is also worth noting that Resolution No. 66.18/2026/NQ-CP, effective from 1 July 2026 to 28 February 2027, which, among other things, provides for certain increased merger notification thresholds. For further discussion of this development, please refer to our previous legal alert available in this link.
For more information on the matters discussed in this update, please contact: our Partner Thang Huynh, Regional Competition Counsel David Fruitman or Senior Legal Advisor Minh Anh Tran.
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
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